Document 14KMq0y9ODY8rBx9yLOqb9va

. .' s *. ( Monsanto ......................- '. = .-teres - General Cffices .... To .".ay 12. 1363 AROCLORS CLEAN-UP FROM PLANT EFFLUENTS Mr. i A Kahn (b) C-O-N-F-IO-E-N-t-I-A-L - Messrs. D E Hosmer* W R Richard S Tjeker E P. Wheeler ' 0 L Eratsch. - * Jackson 3 R. Williams = F B.icleley w. 2 Papageorge J. C. Landwehr W P Taffee E C. Wright At your request (and for your transmittal to appropriate members of the Business Croup), 1 have summarized information on actions, plans and problems at Anniston and at W g Krummrieh to avoid sewering aroclors into natural waters. The Informa tion was obtained from Messrs. V F Taffee (Anniston)'and C. P Buckley (W. G. Krummrlch). - .. ' , ' ' ' ' [ I . I. Analyses of Waste and Natural Water ,Samples' A. General . We have generally taken the position that, before any expensive projects are undertaken to halt sewering of aroclors, we ahould know what levels exist in. the receiving waters. In other words, we need to define problems. If any, resulting from loss of aroclors in the plant effluents. This work Is, of course, de pendent on development or analytical techniques and Implementation of these techniques In the plants (or arrangements to have the samples' analyzed In a single laboratory). . . ' ' General status of this work Is that Gr. Ticker has developed the necessary techniques (ahead of schedule) and has analyzed one lot or- samples from Anniston and will soon have completed analyses of several samples from V, G. Krummrlch. Transmission or analytical methods to the; plants. Is expected du.rlng mid-May. However, problems of manpower priority exist at both plants and, in addition, there Is a problem of equlpment priority at Anniston. Az soon as the laboratory techniques are received and studied by the plants, we need to determine priority of the aroclors testing program In relation to other work and to move to ob tain the necessary manpower and equipment. EDC of study phase - June 1, 1969 (both plants). We will then move to clarify problems of. priority (EDC - June lp, 1969). DSW 013579 WATER PCB-SD0000046796 rrotlens at '/, ~ The necessary electron-capture equipment Is a-ailatls cut only one licenses operator Is available. He -as a f.ll schedule of ocher work laid out for one r.ear .'-Cure, so priorities rust ce established. C. Problems at -nr.iston Electron capture equipment exists at inniston cut it has never ceen used. Considerable developmental work is necessary, therefore, for someone to familiar ize himself with this equipment and then to work out the technique for FC3 content. Another problem is . that of equipment priority because the chromatograph, with which the.electron capture is used, is occupied full time on other high priority work. II Work to Minimize Losses at 'V. G. Krummrich In absence of analytical techniques for actual measurement, a qualitative study of loss sources has been made, The only substantial source (that of occasional sewering of the Therminol from P2S5 production) was Immediately stopped and Instructions nave been Issued throughout the plant that no aroclor Is to be sewered Intentionally. A- Notes on Aroclora Production Department 1. Vlth. the recent years Improvements In chlorir.ator off-gas cooling plus Brink mist eliminators, there is no longer any free aroclor In the HC1 off-gas which comes out In catch pots (at one time mis was considerable). The catch pots never require- draining. _' 2. The only sewered source of loss of slgnlficar.ee Is from leaks, spills, pump packing glands, etc. ' Supervision has moved to minimize these sources, but no positive protection exists-. As policy on any new construction (as being planned for tre aroclor storage tank farm and car loading opera tion), sumps will be provided to capture any spillage. However, no action is presently plan ned to sump the production area. This will se- pend cn need as evidenced by sampling of our plant outfall and the Mississippi ^Iver. 2. Toe only discharge to atnoconere ~s from packag ing, T C loading and spil . ;e (particular:, s co steam traced lines). charges are plar-et. T"e air stream from the blow tanks is tei'g OSW 013580 y WATER PCB-SD0000046797 3 drowned to sewer (this sewered stream ill be tested eventually, c_t Is believed to te insignificant) 2 Other Possible Sources 1. Tank car washing - infrequent, but significant (up to 200 gallons). Warehouse department per sonnel are studying alternates - no major pro ject Is anticipated but minor changes should . virtually eliminate any significant loss. 2. . Miscellaneous Thenninol Systems -- no intentional sewering 13 now made; however, accidental losses can occur. No projects are contemplated at this time, but these systems must receLve high opera ting and maintenance priority to minimize acci dental losses. . 3. HC1 off-gas vapor losses (including spent carbon from HC1 treatment) -- these are believed to be very small but will be measured when analytical techniques are available. Waste water samples are being collected intermittently now for later analysis. . Ill. Work to Minimize Losses at Anniston . A. Definition of Problems 1. External to plant -- that a problem exists at Anniston 13 evident because Tree" globules of aroclors can be seen In Snow Creek. We do not know what problem exists In Choccolocco Creek and the Coosa River. By July 1, 1969-, we will determine the limit of visual evidence of aroclors downstream in Snow Creek. Between this "point of last visible evidence" and the mouth of Snow Creek,"'two sets of mud and water samples for soluble losses will be collected with EDC of analyses targeted for August 1,' 1969. Two sets of.mud and water samples will be taken in Choccolocco Creek -- one about 1/^ mile be low the Snow Creek mouth, the other about 5 - 10 1 river miles further downstream. EDC of analyses A-.gust 1, 1969- OSW 013581 WATER PCB-SD0000046798  Further testing '`ill depend on results from t'-e above sampling. Plans ..111 te ir.ade by Ainruct" 15. 1969- " 2. Internal plant problems -- here Is scr.edule for measurements and controls Inside plant- ' a. Identification of possible sources -- done. b. Audit (measurement) of loss sources - EDC July 1, 1969. c. Recommendations for means to reduce losses to limit of solubility - EDC August 1, 1969. d. Definition of requirements and rough costs to reduce as In (c) above - EDC October 1, 1969. e. Establish continuous monitoring station on Choccolocco Creek (for aroclors and POT and Parathlon) - EDC June 1, 1970. The above schedule Is dependent on obtaining necessary manpower and equipment for the analyti cal work. As mentioned before, there Is no experience with the electron capture equipment and the chromatograph Is utilized full time. . To adequately conduct an investigation and con tinued monitoring program will likely necessitate addition of a chemist plus purchase of a $10,000 ' chromatograph. This problem will be defined by June 1, 1969, with recommendations by June 15. 1969. . Work to Reduce Sewering 1. Aroclors in HC1 -- a catch tank has been instal led In the vapor line near the HC1 absorber. . The aroclors captured are now being hauled to landfill. A coalescer Is being installed to capture aroclor globules in the crude muriatic acid. This'aroclor will be taken to land fill. 2. Thermlnol Systems --no known losses were found from these systems. Spent aroclor from the F2S5.opera cions has teen drummed for hauling to land fill for at least the past several years. 3. Aroclor production department -- an audit of losses Is under way. No aroclors are sewered Intentionally -- losses are or mechanical nat-re. Need for a sump system will be defined by tne 3Jdit and a project(s) will be submitted If justified. ' SV 013582 WATER PCB-SD0000046799 4-. Losses to atr.ospr.ere -- tr.ere are r.o process losses to atmosphere except Tor tank car load . lng, etc. A closed loop loading system is planned for about 1970-1971 (objective is redaction of contamination of aroclor). 5. Tank car cleaning -- this is not a problem at Anniston. No heels are drained to tne se*er. Comments from recipients of this letter are i.-.vlted. ' acd Paul o Hodges OSW. 013583 WATER PCB-SD0000046800